Subject: File No. 4-606
From: Mike Griffin

August 16, 2010

The legislation being considered would damage the financial services industry severely.

We are already one of the highest regulated industries that exist.

These proposed changes will not help the consumer. Advisors will need to charge more for their services to counteract possible lawsuits. With the risk involved in investments, there is no way to know if you are complying with the "best interest" part of this legislation until many years later. The same could be true with any of the decisions you make as a legislator. Only hindsight can be guaranteed.

Fee only advice is not necessarily an advantage to the consumer. Part of an advisor's job is to get people to take action when a plan is in place. If an advisor already received their fee, then there isn't any incentive for them to help coach their clients into taking action. Of course, only bad advisor would act this way, but only bad commission based advisors are causing problem already. It has much more to do with the advisor than it does with the compensation structure.


Mike Griffin